This document contains 10 questions to ask a lawyer about ICOs and cryptocurrency regulations. It summarizes the current regulatory status of ICOs in Bulgaria and the EU, including that there are no supervisory authorities but some informative notices have been issued. It prompts questions about where to base a company, KYC procedures, responsibilities, defining utility tokens and security tokens, taxation obligations, and legally using funds post-token sale. Overall the document provides a checklist of legal and compliance topics to discuss with counsel regarding launching an ICO.

1. vladimir.tasev@os.university

2. 10 QUESTIONS TO ASK YOUR LAWYER?

4. 10 QUESTIONS TO ASK YOUR LAWYER?
1. What is the current status of the ICOs in
Bulgaria?
● Currently in Bulgaria there aren’t any specified regulatory restrictions
● No supervisory authority
● Informative notice from Financial Supervision Commission:
http://www.fsc.bg/bg/novini/eotskp-preduprezhdava-firmite-koito-sa-svarzani-s-
parvichni-predlaganiya-na-virtualna-valuta-ppvv-che-e-neobhodimo-da-otgovaryat-na-
opredeleni-regulatorni-iziskvaniya-8704.html

5. 10 QUESTIONS TO ASK YOUR LAWYER?
2. What is the current status of the ICOs in EU?
● No supervisory authority
● Informative notice from the European Securities and Markets Authority:
www.esma.europa.eu/press-news/esma-news/esma-highlights-ico-risks-
investors-and-firms

6. 10 QUESTIONS TO ASK YOUR LAWYER?
3. Where should my company be based?
● There aren’t any EU-wide restrictions for launching an ICO
● Some countries like Estonia and Germany have some rules about
cryptocurrencies and ICOs

7. 10 QUESTIONS TO ASK YOUR LAWYER?
4. What should I be aware of?
● KYC procedure for every transaction
● How does the government treat
cryptocurrencies?
● Tokenomics!!
Utility tokens; Securities as tokens

8. 10 QUESTIONS TO ASK YOUR LAWYER?
5. What is KYC procedure
and why should we have
such thing?

9. 10 QUESTIONS TO ASK YOUR LAWYER?
6. What are my responsibilities?
● To be able to operate with personal data
● To keep safe all the client’s sensitive data
● Guarantee for the process of selling tokens
● Terms and Conditions

10. 10 QUESTIONS TO ASK YOUR LAWYER?
7. What is a utility token?
● The best case scenario
● The token is in use in the ecosystem of the Platform
● The token is issued as a “Thank you”
● SEC Howey Test

11. 10 QUESTIONS TO ASK YOUR LAWYER?
8. What is a security token?
● Basically a share
● Everything on the regulation side which you need to issue stocks, applies on
the tokens as well
● SEC Howey Test
● The financial commissions still does not issue licenses for such kind of
instruments

12. 10 QUESTIONS TO ASK YOUR LAWYER?
9. Do we owe taxes?
YES.

13. 10 QUESTIONS TO ASK YOUR LAWYER?
10. How to legally use my money after the
token sale?
● Pay your taxes
● Post all of the transactions as they are

14. QUESTIONS ?
Slides will be available at:
https://1legal.net/bg/blog-read126-legal-chains-of-blockchain